Information required by the management of the facility 35

Before a contractor’s employee is accepted into a facility to work in a controlled or supervised area, the management of the facility needs to obtain from the contractor specific information concerning the employee. If this information is immediately available, it will facilitate timely entry to the facility. This information includes:

(a) Details of the appropriate qualifications of the employee (training, experience and certification);

(b) Details of the employee’s occupational dose history;

(c) Relevant information on the employee’s fitness for work and on the employee’s work history that may affect the protection and safety programme developed for the worker.

Some itinerant workers may be assigned tasks to be completed at one facility within a period of days to weeks, and then those workers move to another facility to complete similar tasks in a similar time frame. Some other itinerant workers may, for example, be assigned tasks at one facility two days per week, a second facility two days per week, and yet another facility for one day per week. In this way, some itinerant workers may receive a dose at multiple facilities within a period of one year.

At each facility, the dose received may or may not be substantive; however, the accumulated dose across several facilities in one year (or five years, when relevant) may result in a total dose that may approach the applicable dose limits.

That is one reason that keeping track of the doses of these workers, facility by facility and over relatively long time periods, is important. That is also a reason why thresholds for reporting doses received at a facility are not to exceed a small fraction (under evaluation for specific guidance, but for example 5–10%) of the applicable annual individual dose limits (and are to be low enough to comply with applicable State regulations).

As mentioned in Section 3.1.1 and Appendix I, contractual agreements between the management of the facility and the contractor are to address the allocation of responsibilities for individual monitoring and for record keeping and

record transfer. (In Section I.1.2 of Appendix I, see especially items (g) and (h) in the list of topics to discuss during the development of contractual arrangements.)

There are some States and some cooperatives of registrants and licensees who have developed (or are developing) and who maintain (or plan to maintain) data systems for individual records relating to protection and safety.

Whether those data systems were developed as centralized networks, dose registries or similar systems, the intent for itinerant workers was to collect relevant information on the identity of a worker, the results of health surveillance for that worker and the results of the measurements (or assessments) of reportable doses to the worker for a specified time frame, correlated to the facility at which the worker was occupationally exposed in that time frame and also to the employer of the worker for that time frame. (In some cases, records on completed training related to protection and safety are also included in the system.)

For workers engaged at multiple facilities within a calendar year, the intent was to be able to evaluate for work activity at each facility, the period covered by the work activity and the effective dose (and, where appropriate, equivalent dose and/or committed effective dose) to the individual worker for that period.

With that information in a data system, analyses may be facilitated for confirming compliance with applicable regulations and pointing to possible opportunities for dose reduction and/or other refinements of protection and safety programmes. Such systems may be of more use for analyses of exposures of domestic itinerant workers rather than international itinerant workers. That is because doses received within a State or a (likely State based) cooperative network of registrants and licensees are more likely to be available for analysis than doses received in several States, until the development of transboundary data sharing techniques becomes more advanced.

For the reasons described above, IRMDs may be used as a supplemental (or even primary) means of enabling information to be shared among facilities and, when appropriate, with the regulatory body.

One method for the provision of information to the management of the facility on the dose history and fitness for work of an itinerant worker is the use of an IRMD.

Such an IRMD is a requirement for Member States of the European Union [11], for those situations where a nation’s data system for individual monitoring is not adequately protective for contracted workers, or where necessary to adequately track the doses to contracted workers crossing international boundaries. A revision of these requirements has recently been carried out by the European Union and is now part of the European Basic Safety Standards [12].

The Heads of the European Radiological Protection Competent Authorities are developing guidance on using IRMDs. A description of the IRMD, as it is being

Under this system, each itinerant worker applying for an IRMD is assessed regarding thresholds established by the State regulatory body (e.g. expectation of receiving an annual dose greater than a preselected value).

The itinerant worker meeting the State criteria would then hold an IRMD, issued by an organization authorized by the applicable (State) regulatory body, which contains a summary of the dose history.

That dose history most often consists of official dose results available on the date that the IRMD was issued and estimated doses received by the worker since that date (based on operational dosimetry and/or individual monitoring for intakes of radionuclides).

The IRMD also contains the dates of health reviews of the worker and a space for designated members of facility management (or the employer, depending on the agreed allocation of responsibilities) to enter estimated doses for the worker. The IRMDs are handed to the management of the facility for inspection when the worker arrives at the facility or, at least, prior to the commencement of work at the facility.

As the work evaluation is completed, a designated representative of the management of the facility (or the employer, depending on the agreed allocation of responsibilities) then enters an estimate of the dose received by the itinerant worker while on-site. This estimated dose may be based on the results of individual monitoring or on workplace monitoring and assessment, but the estimated dose provides a useful indication of the worker’s dose for the next facility manager, in case the worker moves to another facility prior to the official record individual monitoring data being entered into the IRMD or its successor.

It is the responsibility of the employer of the itinerant worker to ensure that the IRMD is kept up to date.

In most cases where the worker has moved from one State to another for their work assignment, official and estimated doses are accepted as being accurate, absent available information that the results are suspect or State regulations that do not allow for that choice. Their accuracy can be questioned, in which case information on the reliability of the official and/or operational individual monitoring may be requested and evaluated by the employer and/or the registrant or licensee (and regulatory body, where appropriate).

Additional description regarding an IRMD and an example of its content are given in Appendix II. Not all States use such a system or its equivalent.

Some States may issue IRMDs using content differing in some aspects from the contents described in Appendix II.

As noted above, in some States, electronically based database systems are in use or are in development, which may facilitate provision of operational and official dose results (and other relevant data) to the appropriate parties for conduct of their duties and responsibilities. Some of these electronically based

systems are designed primarily for use by one industrial segment (e.g. nuclear power plants) and others for use by a regulatory body interested in data, both for all individuals receiving exposure in the State and for individuals to whom the electronic equivalent of the IRMD has been provided by the issuing authority of that State.

The data on an itinerant worker’s occupational dose history on which a facility relies may be from a centralized system or dose registry, an IRMD such as a State issued document or a quality assured IRMD maintained by the (worker and) employer based on data reported to the (worker and) employer by dosimetry service providers and/or appropriate facility management. Without the details of an itinerant worker’s occupational dose history, access to supervised and/or controlled areas for work may be denied.

It will also be appropriate for the management of the facility to carry out an assessment of the competence of the contractor’s employees. This subject is discussed in Section 4.

Before work by a contractor at a facility is allowed to begin, the management of the facility also needs to obtain information from the contractor concerning any hazardous materials that the itinerant workers expect to bring to the facility and any non-radiological risks to the facility and its employees which may result from the efforts of the itinerant workers. This information is used in assessing the safety of the proposed work and in developing an optimal work management plan.

3.2.9. Qualified experts

Registrants and licensees and also non-licensed contractors will find it appropriate to consult with qualified experts⁴ on a wide range of issues. It is important that the contractor (and/or the management of the facility) considers whether it needs to consult with one or more qualified experts regarding the work to be undertaken, depending on the nature of the work and any contractual conditions. If the contractor wishes to consult with a qualified expert, it may seek guidance from the management of the facility and/or an independent source for suggestions on suitable persons. The following subjects are examples of those

4 A qualified expert is an individual who, by virtue of certification by appropriate boards or societies, professional licences or academic qualifications and experience, is duly recognized as having expertise in a relevant field of specialization, e.g. medical physics, radiation protection, occupational health, fire safety, quality management or any relevant engineering or

for which guidance may be required from a qualified expert as regards protection and safety:

(a) The review of engineered controls related to protection and safety;

(b) The formulation of suitable local rules and procedures;

(c) Appropriate dosimetry arrangements;

(d) The need for personal protective equipment;

(e) The use of radiation monitoring equipment;

(f) Record keeping;

(g) Emergency procedures.